TB-GR Compliance Action Guidelines--- Contents --INTRODUCTION(1) Compliance with laws and regulations, rules of employment, internal rules, etc.
(2) Conduct in accordance with general social conventions and good sense

COMPLIANCE MATTERS
1. Guidelines for Business Activities(1) Compliance with import/export laws and regulations(2) Stringent security trade control(3) Compliance with industry-specific laws
(4) Compliance with fair trade and related laws
(5) Prevention of unfair competition(6) Protection of intellectual property rights(7) Stringent information management(8) Environment protection2Guidelines for Tokyo Boeki Group as a Corporate Citizen(1) Entertainment and gifts(2) Entertainment and gifts for public officials in and out of Japan(3) Donations and political donations regulations(4) Disassociation from antisocial organizations(5) Prohibition of insider trading(6) Correct use of information system(7) Ban of acts involving conflicts of interest(8) Appropriate accounting and tax procedures

3Guidelines for Maintaining an Ideal Workplace Environment(1) Respect for human rights and nondiscrimination(2) Ban on sexual or workplace power harassment(3) Workplace safety and health1Employees of Tokyo Boeki Group will act in accordance with the following TB-GR Compliance
Action Guidelines in order to realize the “Tokyo Boeki Group Management Axis” and to ensure
implementation of the “Action Guidelines to Embody Management Participated by All”.

INTRODUCTION
If a corporate wrongdoing should happen even once, enormous efforts need to be made to regain trust.
At Tokyo Boeki Group, which seeks to be a first-class corporate group, every employee should be an
important player to put compliance into action in order to meet the expectations of our stakeholders
and contribute broadly to the community and society. As a member of a passionate work team, weeach maintain high hopes and aspire to be an open and fair group of people. As a member of the Tokyo
Boeki Group, which has high business ethics, we are committed to promoting compliance awarenessamong the Group's executives and employees, for example by thoroughly implementing the TB-GR
Compliance Action Guidelines.
Incorporating the following compliance matters into our basic stance, we ourselves fully understandand practice them earnestly.
(1) We will abide by laws and regulations, the Rules of Employment, and internal rules, etc.
① We correctly understand and interpret the laws and regulations relevant to us, and honor
the laws that apply to our respective business areas.
② We will follow the procedures set out in the Employment Regulations and internal rules
and will not take any action that may raise compliance issues. In the unlikely event that acompliance issue arises, we will carry out our work in good faith, while reporting it
immediately to our managers or the relevant department as the basic rule.
③ If we are not sure, we will not make judgment by ourselves but instead disclose theinformation to our managers or the relevant department, discuss with them in depth, andthen act.
(2) We will act in line with general social conventions and good sense.
① We understand the Compliance Action Guidelines and put them into practice.
② If we are not sure, we will disclose the information to our managers or compliance staff,
discusses with them, and act in accordance with the following points.
At all times we ask ourselves whether the path we intend to take is:2

1)

Not in violation of laws and regulations, internal rules or the like2)

Not against socially-accepted morals or common sense3)

Something we can confidently tell about to our families and friends

4)

Something we would not be afraid of if reported in newspaper, TV or other media

5)

In our mind, truly the right thing to do3

COMPLIANCE MATTERS
1.

Guidelines for Business Activities(1) Compliance with import/export laws and regulations① In performing export and import transactions, we will follow due procedures incompliance with relevant trade control laws and regulations, international conventions, etc.

② We will duly follow necessary permit and approval procedures and submit correct
declarations.

③ We will neither export nor import items that are subject to embargo.
(2) Stringent security trade control① We will abide by the trade control laws, Foreign Exchange and Foreign Trade Act andregulations of the countries concerned as well as United Nations resolutions, international
conventions, etc., in order to prevent proliferation of weapons of mass destruction, etc.

② We will not engage in inappropriate transactions to ensure that our reputation is nottarnished by our involvement in trade in cargo or technology that, although not directly
controlled by laws and regulations, could be used or diverted for the proliferation ofweapons of mass destruction.

(3) Compliance with industry-specific laws
① In the conduct of our business, we will obtain necessary permits and licenses and observe
relevant industry-specific laws.

② The Company is committed to ensuring that it does not violate the law in its
domestic or overseas operations.
(4) Compliance with fair trade and related laws
① We will not engage in 'unreasonable restraint of trade', such as cartels and bid-rigging, or'unfair trade practices', such as resale price maintenance and abuse of a dominant position,
which impede fair and open competition between companies.

② We will not exchange information or contact competitors in violation of antitrust and otherlaws and regulations that could affect sales prices or terms, including any action that might
give rise to such a suspicion.

③ We will ensure compliance with antitrust and related laws not only in domestic transactions
but also in transactions with foreign countries, and not only with private companies but4

also with public institutions.

(5) Prevention of unfair competition① We will not acquire, use, disclose or divert trade secrets of our own or of others throughtheft, fraud or other unlawful means.

② We will not use, divulge or divert trade secrets of our own or of other companies, regardlessof whether they were obtained in good faith or otherwise.

③ We will not disclose, offer, transfer or otherwise communicate to third parties any trade
secrets or useful information of our own by any means whatsoever without permission ofthe company.

(6) Protection of intellectual property rights① The company’s intellectual property , which have been obtained from research anddevelopment and other business activities (inventions, utility models, designs, copyrights,trademarks, knowhow, technical information, etc.), are important assets of the company.
We will use them appropriately and work to protect the rights.

② We will without delay file applications for patent, registration, etc. on results attributable
to the company, so that the company’s intellectual property rights should be duly protected.

③ We will not make unauthorized copies of third party computer software or otherwise
infringe upon third party intellectual property rights.

④ We will not make unlawful use of the intellectual property rights of our customers andsuppliers. We will use them only after entering into an appropriate contract.

(7) Stringent information management① We will take the utmost care in managing information within our company and are
responsible not only for the information we hold, but also for the information disclosed to
us by third parties.

② Confidential information, including trade secrets, know-how and personal data, shall beproperly managed to prevent loss, damage or inappropriate use.

③ Thoroughly manage information and reduce the risk of disclosure, for example bydisposing of information that is no longer needed.
(8) Environmental protection① In all aspects of our business activities, we will always be aware of the importance of5environmental protection and abide by laws and regulations relating to the environment.

② Energy saving and recycling are also addressed from the perspective of reducing
the environmental impact of operations.

2.

Guidelines for Tokyo Boeki Group as a Corporate Citizen(1) Entertainment and gifts① Entertainment and gifts to customers and suppliers, when done, shall be within the rangeof social etiquette.

② Entertainment and gifts from customers and suppliers, when receiving, shall always be
within the range of social etiquette.

(2) Anti-Corruption① We will not accept or promise or offer to accept any money or other benefits from domestic
or foreign public officials or similar persons for the purpose of obtaining improper businessadvantage or in return for business favours.

② If we are asked to take any of these actions by public officials or similar persons, we willrefuse to do so and will contact the appropriate authorities as the situation requires.

(3) Donations and political donations regulations① Political donations and donations to organizations in general, when done, shall be madefollowing correct procedures in compliance with the Public Offices Election Act, PoliticalFunds Control Act and other relevant laws and regulations.

② Donations shall be made only after approval in accordance with internal rules.
③ Not to mention bribery, payoffs and illegal political donations, we will strictly refrain fromtaking actions that could be misunderstood as collusion with politicians and administration
officials, and will work to build healthy and transparent relations.

(4) Disassociation from antisocial organizations① We will have the basic legal knowledge, common sense and sense of justice not to be
involved in unlawful or antisocial conduct, and we will strive to always act sensibly.

② We stand firmly against anti-social forces that threaten the order and safety of our civic
6society and in no way have association with such forces. If we receive any undue demand
from an anti-social organization or the like, we will react sternly and will not attempt toreach a solution by offering money or the like.

③ We will not make use of anti-social forces in an attempt to make gains for ourselves or forthe company.

④ We will not make any transactions with anti-social forces or customers or suppliers havingtransactions with such forces.

(5) Prohibition of insider trading① We will not use insider information of our customers and suppliers, competitors and clientsthat we have come to know in the course of doing our business for the purpose of buying
or selling the shares or bonds of such companies prior to disclosure of such information togeneral investors, nor do we take any action that could lead to such suspicions.

② If we become aware of inside information, we will handle it appropriately in accordancewith our internal rules and keep it strictly confidential.

(6) Correct use of information systems① We will use the company information systems only for the conduct of business and not for
personal purposes.

② We will control ID’s and passwords for the company information systems strictly andprevent leakage, theft or destruction of confidential information as well as contaminationby computer viruses and other damages.

③ We will neither steal ID’s or passwords of others nor make unauthorized access to thesystems of this or other companies.

④ We will use the Internet always in an appropriate way and not commit acts that could
destroy our social credibility.

(7) Prohibition of acts involving conflicts of interest① We will execute the company’s business sincerely and will not commit acts that would run
counter to the interests of the company.

② We will neither do harm to the honor and credibility of the company, nor unduly impair ordamage tangible and intangible assets of the company.

③ Unless concurred by the company, we will not engage in other jobs, become an officer of7

another company, or conduct a business of our own.

(8) Appropriate accounting and tax procedures① We will make entries into books and slips and otherwise prepare books of account incompliance with applicable laws and regulations and internal rules.

② We will not disguise or conceal facts, make false or nonexistent statements, or build offthe-book assets.

3.

Guidelines for Maintaining an Ideal Workplace Environment(1) Respect for human rights and nondiscrimination① We will work to maintain a sound workplace environment at all times, respect thehuman rights of the members and commit no acts that could lead to discrimination.

② We will not conduct any irrational discrimination whatsoever based on birth, nationality,race, ethnic background, creed, religion, gender, age, physical characteristics, hobbies
and orientation, educational background, etc.

③ We will not infringe upon the human rights of others by violence, shouting, libel orinsult, forced labor through threat, bullying, etc.

(2) Prohibition of sexual or workplace power harassment① We will not sexually harass others, commit acts that may be misunderstood as sexual
harassment, or make sexual statements or acts that make others uncomfortable.

② We will not take advantage of our positions in the workplace to cause physical pain toother employees, invade their personal rights, or deteriorate the workplace environment.

③ Furthermore, we will not commit acts that could make others uncomfortable against
their will.

(3) Workplace safety and health① Placing the highest priority on safety and health, we will work to improve ourworkplace environment, and understand and comply with laws and regulations relating
to work safety and health.

② If a work-related accident should occur, we will not fail to immediately report andfollow other prescribed procedures in order to contain the accident to the minimum andto prevent recurrence.
89First revision:

August 1, 2016

Second:October 25, 2017

Third:

January 30, 2018

Forth:

April 1, 2023